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US DOJ Outlines New Enforcement Priorities for Corporations and Individuals

On Wednesday, February 5, 2025, the newly confirmed Attorney General (AG) Pam Bondi issued fourteen memoranda to all Department of Justice (DOJ or the “Department”) employees regarding a wide range of new policies and...more

US Commerce Department Finalizes Rule on Connected Vehicles With Supply Chain Links to China and Russia

On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) addressing national security concerns regarding information and communications technology...more

US Department of Commerce Issues Interim Final Rule Designed to Protect American AI

On January 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) titled “Framework for Artificial Intelligence Diffusion.” The IFR builds on a long series of...more

President Biden Issues Executive Order on Strengthening and Promoting Innovation in the Nations Cybersecurity

INTRODUCTION... On January 16, 2025, President Biden issued an Executive Order (EO) on Strengthening and Promoting Innovation in the Nation’s Cybersecurity, to further address increasing threats from nation-state actors...more

Export of Sensitive Personal Data: US Department of Justice Issues Final Rule to Regulate

On December 27, 2024, the Department of Justice (DOJ) released a Final Rule, Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons....more

US Department of Justice Issues Long-Awaited Proposal to Revamp Regulations Implementing the Foreign Agents Registration Act...

On December 20, 2024, the US Department of Justice (DOJ) issued a long-awaited notice of proposed rulemaking (NPRM) to revise regulations under FARA, three years after an Advance Notice of Proposed Rulemaking sought input on...more

The US Foreign Agents Registration Act (FARA): Key Issues to Watch in 2025

After yet another banner year for the Foreign Agents Registration Act (FARA)—including high-profile prosecutions, an all-time high in registrations, a record number of inspections, and a key DC Circuit decision—US Department...more

Biden Administration Issues First-Ever National Security Memorandum on Artificial Intelligence

On October 24, 2024, President Biden issued the first-ever National Security Memorandum (NSM) on artificial intelligence (AI), fulfilling another directive (subsection 4.8) set forth in the Administration’s Executive Order on...more

Department of Justice Issues Notice of Proposed Rulemaking to Regulate Export of Sensitive Personal Data

On October 21, 2024, the Department of Justice (DOJ) released an unpublished Notice of Proposed Rulemaking (NPRM), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by...more

US Department of Commerce Issues Proposal to Require Reporting Development of Advanced AI Models and Computer Clusters

On September 9, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (BIS) released notice of a proposed rule to create a mandatory reporting requirement for artificial intelligence (AI)...more

BIS Adopts Additional Controls on Quantum, Semiconductor and Additive Manufacturing Technologies in Concert with International...

On September 6, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) issuing new export controls on quantum computing, semiconductor, and other advanced technology,...more

US Justice Department Continues Focus on Criminal Enforcement of FARA

As predicted earlier this year in our January update, the US Department of Justice (DOJ) has continued to ramp up enforcement of the Foreign Agents Registration Act (FARA) and related political laws through criminal...more

US DoD Proposes Final Rule to Incorporate Contractual Requirements for the Cybersecurity Maturity Model Certification (CMMC)

On August 15, 2024, the Department of Defense (DoD) published a proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate contractual requirements related to the Cybersecurity...more

CFIUS Announces $60 Million Penalty and Debuts New Enforcement Website

On August 14, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) announced a $60 million penalty, “the largest penalty CFIUS has ever issued,” following its finding of material violations...more

BIS Issues First ICTS Ban, Prohibiting Sales and Updates to Kaspersky Products and Services in the US, while OFAC Sanctions Senior...

On June 20, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) issued a Final Determination (“Determination”) prohibiting Kaspersky Lab, Inc.—the US subsidiary of the Russia-based antivirus software and...more

US DoD Issues Class Deviation Delaying DFARS Implementation of Upcoming NIST SP 800-171, Revision 3

On May 2, 2024, the Department of Defense (DoD) issued a class deviation to DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting. The deviation relates to contractors’ compliance with...more

US Congress Extends Statute of Limitations for Sanctions and Export Controls

On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the “Act”). While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill...more

US DOJ’s National Security Division Updates Enforcement Policy for Criminal Sanctions and Export Control Violations with New Focus...

On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...more

Commerce Considers ICTS-related Rules to Address Connected Vehicle Risks

On March 1, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (“BIS”) published an Advance Notice of Proposed Rulemaking1 (the “Notice”) seeking public comments on potential regulation of the...more

Department of Commerce Seeks Comment on Proposed CIP Requirement and Foreign Access Restrictions for US Infrastructure as a...

On January 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (the “Department”) issued a notice of proposed rulemaking seeking comment on a proposed regulation in response to the Executive Order (E.O.)...more

The US Foreign Agents Registration Act (FARA): Key Issues to Watch in 2024

With recent high-profile prosecutions continuing to draw attention to the Foreign Agents Registration Act (FARA) and related political laws, and a number of notable announcements by Department of Justice (DOJ) officials at a...more

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